Under the PMLA, property acquired before a scheduled offence is not ordinarily directly derived from later criminal activity, but may be provisionally attached as the equivalent value of unavailable or dissipated proceeds of crime under the broader interpretation of the value limb. Attachment requires an identified scheduled offence, a reasoned assessment of illicit proceeds and equivalent value, and written reasons based on material showing a real risk that the property may be concealed, transferred or otherwise dealt with to frustrate confiscation. Income-tax disclosure is relevant but not conclusive. Statutory adjudication must allow the affected person to establish lawful source, challenge the asserted nexus and address valuation.

Proper-officer jurisdiction under customs law depends on an officer's appointment and function-specific assignment, rather than merely designation, investigation role, or original assessment. Assessment under Section 17 and recovery notice powers under Section 28 are distinct; the notice need not be issued by the officer who assessed the goods. Section 28(11) retrospectively validates qualifying customs officers' assessment powers and proper-officer status, unaffected by Explanation 2's preservation of the earlier recovery regime. Confiscation or penalty proceedings require separate compliance with Section 124, including written grounds, prescribed prior approval, representation, and hearing. Once jurisdiction is established, factual, limitation, evidentiary, and procedural objections remain for adjudication.

Dependent agent permanent establishment under Article 5(5) of the India-Switzerland DTAA requires cogent evidence that an Indian intermediary both has authority to negotiate and enter contracts for the foreign enterprise and habitually exercises that authority. Customer liaison, account management, administrative support, communicating pre-approved terms, and assisting an online contracting process do not satisfy that test where material commercial decisions remain offshore. Group control or economic dependence cannot replace the positive authority requirement, though they may affect independent-agent status. PE existence must be determined before Article 7 profit attribution; arm's-length remuneration does not itself prevent a DAPE, but may affect attribution if a PE exists. Rule 10 becomes relevant only where income cannot be definitely ascertained.

GST Council process-reform recommendations cover simplified registration, return filing, refunds, adjudication, dispute management and improved Input Tax Credit flow. Proposed measures include removal of GST arrest provisions, an increased prosecution threshold, reduced maximum general penalties, simplified registration for small e-commerce sellers, and facilitation of inter-State goods movement. GST applicability, rates, exports and trade-facilitation issues are also addressed. Implementation is contemplated through notifications, circulars and legislative amendments, supported by FAQs.

GST treatment of an assignment of existing leasehold rights in an industrial plot depends on the legal character of the rights transferred, rather than the label assigned to the payment. Where the incoming party replaces the outgoing lessee for the balance term, the transaction is an assignment of an existing interest in immovable property, not ordinary renting. Under the Gujarat High Court approach applied to covered GIDC assignments, the purchaser obtains benefits arising from immovable property rather than a taxable service merely because consideration is paid.

GST reconciliation aligns accounting records with GST portal data and periodic returns to ensure that reported supplies, tax payments and input tax credit claims correspond. Purchase registers should be matched with GSTR-2B, sales registers with GSTR-1, and GSTR-1 liability with GSTR-3B tax payment. ITC claims require review of eligible GSTR-2B invoices, blocked credits, reversals, reverse-charge transactions, import credits and supplier credit notes. Invoice-level exceptions should be documented, followed up with suppliers, and corrected through permitted return mechanisms.

Departmental GST appeals below the prescribed monetary threshold require a demonstrated, recognised exception; routine approval to challenge an adverse appellate order does not by itself satisfy the condition for pursuing the appeal. Under the Uttar Pradesh Goods and Services Tax Act, 2017, the Commissioner may prescribe litigation limits on GST Council recommendations, making the limit a statutory litigation-control mechanism rather than a discretionary administrative preference.

Section 112(2) permits discretionary admission of low-value appeals where an important legal issue arises. The third proviso to Rule 138(3) permits Part B vehicle details to remain unfilled when goods move within fifty kilometres in the same State or Union territory from the consignor to the transporter for further transportation. Section 129(1) requires an actual contravention; a qualifying permitted omission is not a breach, and questions of intent arise only after a breach is established.

Extended limitation for recovery of allegedly short-paid central excise duty requires allegations and supporting material showing collusion, wilful misstatement, or suppression of facts with intent to evade duty. Regular monthly returns verified by the Department and a bona fide interpretative claim to concessional duty may negate suppression. Where those ingredients are unproved, an audit objection alone cannot sustain the extended period, and a demand based entirely on it is unsustainable.

Rectification cannot be used to obtain reappreciation of evidence where no error apparent on the record exists, and factual disputes cannot be reopened in an appeal limited to substantial questions of law. Rejection of rectification and objections seeking factual reassessment therefore remains undisturbed. A three-month interval between conclusion of hearing and pronouncement, attributable to heavy pendency, does not by itself invalidate the Tribunal's order. Personal penalties are sustainable where a person deals with excisable goods known or reasonably believed to be liable to confiscation, as permitted under Rule 26 of the Central Excise Rules, 2002. Confiscation and penalty findings consequently remain effective.

Rule 6(5) of the CENVAT Credit Rules, 2004 permits full credit for specified input services used for both taxable and exempt output services unless the input service is used exclusively for exempt services; separate credit accounts are not determinative. After renting of immovable property became taxable, input-service credit must be assessed by the nexus between the input service and the taxable renting output service, rather than by treating the immovable property itself as the relevant test. Fit-out infrastructure forming part of leased office premises is included in the leasing consideration for service-tax purposes. VAT payment does not independently exclude service-tax liability where both levies' factual requirements are met.

Section 107 confines the First Appellate Authority's power to condone delay to the expressly prescribed outer limit; equitable relief under Article 226 cannot enlarge that statutory jurisdiction. Condonation beyond that limit is therefore without jurisdiction. Restoration of taxpayers' registrations following implementation of appellate orders materially changes the parties' position, making subsequent departmental relief to unsettle those orders ineffective and potentially disruptive to intervening transactions and input-tax-credit consequences. The appellate remedy against registration cancellation remains independent of the revocation mechanism under Rule 23, so inability to seek revocation through the common portal does not extinguish the right to appeal.

Section 107 of the CGST Act confines the First Appellate Authority's power to condone delay to the statutory outer limit; extraordinary relief under Article 226 cannot enlarge that jurisdiction. Registration restoration implemented by the Department creates altered legal and commercial consequences, so relief seeking to unsettle the restored status requires addressing those consequences. Expiry of the period for revocation applications under Rule 23 does not extinguish the separate statutory right to appeal a registration cancellation under Section 107. The principles distinguish statutory appellate remedies from revocation procedures and prevent equitable considerations from overriding express limitation periods.

Confiscation proceedings must provide a real and reasonable opportunity to reply and be heard. Where a show-cause notice allows seven days for a written response, issuing a confiscation order on the date of service, before that period expires and without objections, breaches principles of natural justice. A direction to appear on that date does not cure the lack of effective opportunity. Payment made to secure release of detained goods and conveyance does not constitute admission, acquiescence, or waiver of the right to contest the demand. The confiscation and consequential demand require fresh adjudication after allowing a written reply and personal hearing.

Input tax credit eligibility is assessed when invoices are issued by a supplier shown as registered with a valid GSTIN, rather than being automatically defeated by later retrospective cancellation of that registration. Retrospective cancellation preserves the supplier's prior tax liability but does not itself invalidate earlier invoices or withdraw recipient credit. Actual tax payment may be evidenced by GSTR-2A and filed GSTR-3B where payment is admitted. A demand cannot be sustained on alleged non-payment or doubts concerning supplies where those grounds were absent from the show cause notice and the recipient's evidence remains unchallenged. Credit requires statutory conditions to be met at the time of supply; cancellation may justify inquiry but not automatic denial.

Section 109(5) of the CGST Act permits the Principal Bench of GSTAT to hear matters pending before different State Benches where they involve an identical question of law and the President is satisfied that such identity exists. The provision applies to eight appeals concerning refund of interest paid on tax discharged through the electronic credit ledger after retrospective substitution of the proviso to Section 50(1). Their common legal question places them for hearing before a Division Bench of the Principal Bench.

Separately generated e-way bills against the same invoice may indicate additional taxable outward movements where electronic bill numbers, validity periods, vehicles or movement particulars are distinct and remain unreconciled. Rule 138 permits changes of conveyance through Part-B updates and, in exceptional circumstances, extension of an existing e-way bill; a fresh e-way bill does not conclusively establish a second supply. Under Section 73, the Department bears the burden of establishing tax short-payment, while continuity of transport, trans-shipment and vehicle changes are matters particularly within the taxpayer's knowledge. Continuity may require contemporaneous delivery, transporter, recipient, toll or other transport evidence. Tax liability can arise without fraud, wilful misstatement or suppression, with delayed payment attracting interest and the prescribed penalty.

Transitional input tax credit carried forward under section 140(1), where the TRAN-1 declaration exceeds balances in pre-GST ER-1 and ST-3 returns, requires verification against relevant records through a reasoned order before eligibility is determined. Invocation of section 74(1) requires material proving fraud, wilful misstatement, or suppression of facts with deliberate intent to evade tax; incorrect information or ordinary non-declaration alone is insufficient. In the absence of investigation or evidence of deliberate intent, the fraud-based notice cannot be sustained, while the credit claim remains subject to factual verification.

GST registration cancellation and revocation are governed by the CGST Act and Rules. Issuance of a show-cause notice before cancellation defeats a claim that no opportunity of hearing was granted. In the stated circumstances, cancellation-related orders were set aside, subject to complete filing of pending GST returns, correction of incorrect nil-liability returns, and payment of costs. Revocation of registration must then be considered in accordance with law.

GST registration cancelled under the earlier revival framework may be restored only after pending pre-cancellation returns are filed and outstanding tax, interest, and applicable fine or fee are paid. Post-cancellation returns must also be filed, with GST paid in cash. Input tax credit may be utilised only after scrutiny and approval by the competent authority. Compliance with these conditions permits restoration of the cancelled registration and setting aside of the cancellation.